Section 92 → Section 180
Computation of income from international transaction having regard to arm's length price
Quick Answer
Section 92 of the Income Tax Act, 1961 (Computation of income from international transaction having regard to arm's length price) corresponds to Section 180 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 92
Section 92 of the 1961 Act sets out the rules on computation of income from international transaction having regard to arm's length price. The charging section for Transfer Pricing. Mandates that any income arising from an international transaction must be computed using Arm's Length Price (ALP).
Under the Income-tax Act, 2025 (effective 1st April 2026), Section 92 is retained and renumbered as Section 180 of the Income-tax Act, 2025. Retained verbatim. The cornerstone of anti-profit shifting laws.
The transition impact on Section 92 is assessed as Critical. Governs all Multi-National Corporations (MNCs) operating in India.
Sec 92
Provision Summary
The charging section for Transfer Pricing. Mandates that any income arising from an international transaction must be computed using Arm's Length Price (ALP).
Sec 180
Provision Summary
Retained verbatim. The cornerstone of anti-profit shifting laws.
Key Changes & Highlights
- Explicitly states that if ALP calculation reduces the total taxable income in India, the provision will not apply.
Related Sections
Frequently Asked Questions
Which subject does Section 92 of the 1961 Act cover?
Section 92 of the Income Tax Act, 1961 covers computation of income from international transaction having regard to arm's length price. The charging section for Transfer Pricing. Mandates that any income arising from an international transaction must be computed using Arm's Length Price (ALP).
What is the new section number for Section 92 under the Income-tax Act, 2025?
Section 92 of the Income Tax Act, 1961 maps to Section 180 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained verbatim. The cornerstone of anti-profit shifting laws.
How does the Income-tax Act, 2025 affect Section 92 in practice?
The transition impact for Section 92 is rated Critical. Governs all Multi-National Corporations (MNCs) operating in India.
What is new about Section 92 under the Income-tax Act, 2025?
Explicitly states that if ALP calculation reduces the total taxable income in India, the provision will not apply. These points are specific to Section 92 (Computation of income from international transaction having regard to arm's length price).
Disclaimer: This mapping of Section 92 (Computation of income from international transaction having regard to arm's length price) to Section 180 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 92 is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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